On behalf of The Loan Syndications and Trading Association (LSTA), Financial Services partners David Dickstein, Richard Marshall and associate Phillip Koh prepared a comment letter on the Securities and Exchange Commission's package of proposals relating to the standards of conduct for registered investment advisers and the delivery of Form CRS to their advisory clients. The comment letter argued for an exception from the Form CRS requirement for investment advisers dealing only with "qualified clients" under Investment Advisers Act Rule 205-3. The letter also supported other recommendations made by the Investment Advisers Association (IAA). ("LSTA Submits Comment Letter on SEC Fiduciary Standard Proposal," August 9, 2018)